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2006 (3) TMI 69 - HIGH COURT BOMBAYAppellant could not establish that the money deposited by it under protest was in the capacity as ‘manufacturer’ - appellant could take benefit of the legal position of non-applicability of the limitation of six months to the claim for refund only if it satisfied that the amount was deposited by it as ‘manufacturer’ under protest - duty was deposited on 16-2-1991 - application for refund u/s 11B was made on 4-6-1993 - application is time barred - No substantial question of law arises
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